Recommendation #2 To: Health Care Services, Department of

If Health Care Services continues using audits to ensure that providers comply with Medi-Cal billing procedures for medical equipment, including the upper billing limit, it should design and implement a cost-effective approach that adequately addresses the risk of overpayment and ensures that all providers are potentially subject to an audit, thereby providing a deterrent for noncompliance.

Annual Follow-Up Agency Response From October 2012

Audits & Investigations (A&I) has completed all Upper Billing Limit (UBL) reviews except for which which is in progress. The UBL audits were effective in identifying providers who were out of compliance with the billing requirements and in identifying for recovery amounts overpaid. All identified providers received Civil Money Payment letters which identified the billing errors and the consequences of future non-compliance. All providers will be subject to re-audit in six months to verify compliance. Providers who are not in compliance with the billing requirements will be subject to administrative and financial sanctions. A&I considers this matter as being resolved.